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This information is provided by THE MARKET PropCo S.r.l. to those clients (“Data Subjects”) who make purchases or participate in any initiatives organized at San Marino Outlet, or who use other services made available by the Outlet. Personal data will only be used in accordance with:

• EU Regulation no. 679/2016 (hereafter “Regulation”);

• Law no. 171/2018 of the Republic of San Marino (hereafter “Law”);

• the guidelines of the relative Guarantor.

DATA CONTROLLER, DPO and OFFICE RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA 

The  Data Controller is THE MARKET PropCo Srl (hereafter referred to also simply as “THE MARKET”), with registered office at  Strada degli Angariari 41 – 47891 Falciano (RSM), C.O.E. 26567, in the person of its legal representative pro tempore, Email: privacy@themarket.sm.

The Data Controller has appointed a DPO, who can be reached by e-mail at dpo@themarket.sm or by writing to the address of the THE MARKET.

The Representative in the European Union for the processing and use of personal data is the company Promos Development Srl, with registered office at Via San Zeno no. 173, 25124 – Brescia, fiscal code and V.A.T. No. 04444270989, in the person of its legal representative pro tempore, Email: rappresentanteUEsanmarinoutlet@gmail.com;

The company responsible for processing personal data, in its role as business and marketing manager in charge of handling relations with the users of the Outlet, is Promos S.r.l. – fiscal code and V.A.T. no.: 03123920179 – Via San Zeno, 173- 25124 Brescia (BS), Phone: +39 030 2422862,- email: privacy@promosgroup.it, with Stable Organization in San Marino in Falciano, Strada degli Angariari 41.

The Data Processor also has its own DPO who can be reached at the email address dpo@promosgroup.it , at the telephone number +39 030 242 2862 or by writing to the company offices.

1. Data subject to processing 

The Data Controller collects the following types of personal data relative to the Data Subjects (hereinafter, the “Data”) directly from them when they visit the Outlet (for example, to participate in initiatives or events) and when they make purchases there, or use the services provided by the Outlet.

• Personal data, including first and last name, date and place of birth of the data subject;
• Contact data, such as address, phone number and email address of the data subject; 
• Data about the initiatives in which the Data Subject has participated, for example, events organized at the Outlet;
• Data on the level of satisfaction, i.e., information provided in response to surveys, questionnaires and opinion polls; and
• additional personal data relative to Data Subjects, supplied when requesting technical assistance and customer support.

The Company never collects and/or processes particular categories of personal data, including health data, pursuant to article 9 of the Regulation or art. 8 of the Law. Where such data should be collected, even involuntarily, by the Data Controller, they will be deleted immediately, unless effectively necessary for the pursuit of the aforementioned purposes. In that case, however, the Data Controller will inform the Data Subjects promptly and adequately with respect to the methods and purposes of use of specific categories of personal data, in respect of the provisions of the legislation on the subject of the applicable data protection.

2. PURPOSES AND LEGAL BASIS FOR PROCESSING DATA

The Data Controller processes the data relative to Data Subjects for the following purposes and on the following legal basis:

a) to provide the services requested by the Data Subject and offered by the Outlet, and to fulfill possible requests for information or assistance, reports and/or claims presented by Data Subjects (purposes of assistance): (Legal basis) to respond to the specific requests of Data Subjects;
b) issue Outlet Cards entitling the clientele to receive the benefits and participate in the initiatives reserved to card holders (purposes of building fidelity): (Legal basis) the need to perform the provisions of the contract;
c) fulfill obligations deriving from the applicable standards in connection with the offer of goods and services at the Outlet, and perform activities of an organizational and administrative character required by the applicable legislation necessary to guarantee the security of the data subjects on the occasion of events organized at the Outlet (administrative purposes): (Legal basis) fulfilment of legal provisions;
d) with the prior consent of the data subject, to send business communications using traditional means of communication such as email, text and video messaging, instant messages, mobile applications, banners, mail and telephone, to promote the Outlet and the products and services offered by it, or events or other initiatives organized on its premises (marketing purposes): (Legal basis) consent;
e) to send advertising messages via email to individuals who have made purchases and to promote goods and services of the same type as those purchased by them (soft spam purposes): (Legal basis) legitimate interest;
f) to ascertain, exercise or defend a right of the Data Controller in lawsuits (purposes of protection): (Legal basis) legitimate interest of the Data Controller.

The provision of data for purposes of assistance, building fidelity and administrative uses is necessary to engage in the relationship with the Data Controller.  

The provision of data for marketing purposes (letter d) is optional and is based on the consent of the Data Subject. In any case, Data Subjects can revoke their consent at any time and at no charge, and can opt out of receiving business communications, by clicking on the specific link at the bottom of the relative email messages, or by sending a message as described hereafter in paragraph 5 of this Informative Document.

The provision of data for soft spam, strategic and security purposes is not necessary and the Data Subject may object to such use in the manners described herein. But if the Data Subject should object to such use, the data will not be able to be used by the Data Controller, except in case of proven legitimate need or for the exercise or defense of a right pursuant to art. 21 of the Regulation and Law.

2. Processing methods and term of data conservation

Data will be processed both manually and digitally, and only for the time necessary to achieve the purposes of the Data Controller. The logics and procedures of processing are related to the purposes specified in this information sheet. Fully automated decisional processes that produce legal effects for the data subjects or affect them in significant ways are not used.

Data will be kept:

-for purposes of assistance (letter a) for a term of 12 months;

-for purposes of building fidelity (letter b), for the time necessary to attribute the benefits and enjoyment of the initiatives reserved for fidelity card holders;

-for administrative and security purposes (letters c and f), for a term of 10 years, or longer, in case of any disputes that might arise;

-for purposes of marketing and soft spam (letters d and e) the Data will be processed until consent is revoked or withdrawn by the Data Subjects.

After the above terms, the data are deleted or rendered anonymous and used to perform statistical and aggregate analyses serving for a better understanding by the Data Controller of its clientele and the possible definition of more effective business strategies.

3. Recipients of personal data

Personal data may be communicated to third parties for the purposes indicated above, and processed by them as data processors or independent data controllers.  

4. Transfers of data to other countries

Some of the personal data of users are shared with recipients that may be located outside of the Republic of San Marino and the European Economic Community (EEC). The Data Controller guarantees that any processing of personal data by these recipients is done in respect of the Law and Regulation and, in any case, with full application of adequate security. Indeed, such transfers are based on a decision of adequacy or on the Standard Contractual Clauses approved by the European Commission. 

5. Rights of Data Subjects and how to exercise them

The articles from 15 to 22 of the Law and Regulation grant data subjects specific rights that they may exercise. Art. 15 recognizes of the Regulation the right of data subjects to access their personal data and obtain a copy. The right to obtain a copy of their data shall not infringe on the rights and freedoms of others.

With the request of access, data Subjects have the right to obtain from the Data Controller confirmation or denial of the fact that their data are being processed and to know the purposes and categories of data involved, the third parties to which they have been communicated and whether the data have been transferred to a country outside Europe with adequate guarantees. The data subjects also have the right to know for how long their personal data will be used, in respect of the aforementioned purposes.

With respect to their personal data, data subjects may request correction of incorrect data and completion of incomplete data, as well as deletion (right to oblivion) at the conditions indicated by art. 17 of the Regulation, and may request limitation of processing and portability of data.

To exercise the above right, it is necessary to contact one of the following parties:

– the Data Controller at the email address privacy@themarket.sm or the DPO at the address dpo@themarket.sm, or by writing to the address of the registered office of THE MARKET;

– the Representative in the European Union at the email address rappresentanteUEsanmarinoutlet@gmail.com  or by writing to the address of its registered office at Via San Zeno n. 173, 25124 – Brescia. 

Before responding, it may be necessary to identify the data subjects by asking them to supply a copy of their identity document. The data controller will provide a written answer without undue delay and, in any case, no later than one month after receipt of the request. 

6. Claims with the Guarantor for the protection of personal data

Data subjects who believe that use of their personal data violates the provisions of the Law, the Regulation or, more in general, the norms on the subjects of the protection of personal data, may file a claim:

– if they reside or work in the Republic of San Marino, or the violation occurs there, to the Guarantor for the Protection of Personal Data (www.garanteprivacy.sm), as provided by art. 66 of the Law, or to apply to the appropriate judicial authorities (art. 70 of the Law);

– if they reside or work in the European Union, or the violation occurs there, to the Italian Guarantor for the Protection of Personal Data  (www.gpdp.it), as provided by art. 77 of the Regulation, or to apply to the appropriate judicial authorities (art. 79 of the Regulation).

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I, undersigned__________________________, having read the information pursuant to articles 13 and 14 of the Regulation and Law, as indicated in the client information published on the website www.sanmarinooutlet.com  

Consent    □ Do not consent □

to the use of my personal data for purposes of marketing and to receive the newsletter and other informative communications of the Data Controller, such as offers, initiatives, etc., via email, text and video messages and other types of instantaneous messaging, in addition to the traditional advertising methods (telephone calls, regular mail.) 

Signature Date